In the 1990 case of In re Michael Sindram, the United States Supreme Court addressed a recurring issue with one petitioner's excessive and frivolous filings. Michael Sindram was known for repeatedly filing petitions that lacked merit or were irrelevant to his original cases. The court had previously warned him about this behavior but he continued unabated. As a result, in an effort to curb such misuse of judicial resources, the Supreme Court issued an order prohibiting Sindram from further filings unless he first obtained permission from a Justice who would review his submissions for relevance and validity before accepting them into court records. This decision marked one of several instances where courts have taken steps to limit access by vexatious litigants who abuse legal processes through repetitive or nonsensical claims.

In the dissenting opinion for In re MICHAEL SINDRAM, 1990, Justice Marshall expressed concern about the majority's decision to deny Sindram's petition without providing a reason. He argued that this approach could undermine public confidence in the justice system because it leaves people guessing as to why their petitions were denied. Furthermore, he pointed out that such an approach is inconsistent with previous court decisions which emphasized transparency and accountability in judicial proceedings. Justice Marshall also criticized the majority for not giving due consideration to Sindram's claim of being deprived of his constitutional rights by lower courts' rulings against him. He believed that every citizen has a right to seek redress from higher courts when they believe their rights have been violated by lower courts' decisions.